Article 723 of Japan’s Civil Code allows a court, at the request of the victim of defamation, to order “measures appropriate to restore the reputation,” in place of or together with damages. One such measure is a shazai kōkoku, an apology advertisement.
On July 4, 1956, the Grand Bench of the Supreme Court ruled on whether such an order violates the freedom of thought and conscience in Article 19 of the Constitution. It held that an apology that only states the truth of the matter and expresses regret does not.